The Regulation of Geoengineering - Science and Technology Committee Contents

Memorandum submitted by the Sustainability Council of New Zealand (GEO 08)


  Although governments have a duty under the UN Framework Convention on Climate Change (FCCC) to avoid "dangerous" climate change, the treaty does not specify what concentration of greenhouse gases would constitute a safe level. In absence of this, international negotiations have operated on the basis that limiting the average rise in global temperatures to 2°C will be sufficient. It has also been widely assumed that if the concentration can be stabilised at 450 parts per million equivalent (ppme),[11] this would provide a 50% chance of holding the temperature rise below that 2°C limit.

  A 50% chance of avoiding dangerous outcomes is a very low level of protection for an intergenerational endowment. Yet international negotiations to date have implicitly targeted concentrations of 450 ppme and above. Further, the modelling behind these estimates excludes what are termed "slow" feedback effects—changes to ice sheets and vegetation.

  If climate models are required to deliver an appropriately high chance of keeping within the 2°C target, and also to account for slow feedback effects, the world's "carbon" budget is already overspent. Citing a changed understanding of the timescale for slow feedback effects, James Hansen of NASA last year revised down his estimate of a "safe" concentration for CO2 alone to 350 ppm—meaning less than 400 ppme for all gases. This is below today's level and would require that a significant volume of greenhouse gases be extracted from the atmosphere.

  In contrast, the plan to confront global warming that is the current focus of international negotiations is based simply on cutting emissions. It assumes that the atmosphere can absorb sufficient additional carbon to allow a prompt but unhurried transition to a low carbon economy. However, a truly low risk and precautionary plan would require not just cutting emissions but also reducing the existing concentration by extracting CO2 from the atmosphere.


  Avoiding dangerous climate change will require a new plan that makes use of a mixture of options. There is a clear hierarchy of preferred measures:

    1. Abatement: reducing greenhouse gas emissions;

    2. Sequestration: removing greenhouse gases from the atmosphere; and

    3. Reflection: limiting warming by reflecting or blocking sunlight.

  Immediate options for large-scale sequestration are biologically based and dominated by afforestation, while the capture of CO2 from the air by chemical reaction is seen as the key emerging technology.

  If all the sequestration capacity estimated to be available were used together with responsible rates of abatement, this would be almost enough to absorb both new and historic emissions at a rate sufficient to deliver a 380 ppme concentration by 2050. While new techniques may well raise future estimates of the available capacity, it remains uncertain what proportion of the technical potential could be accessed in practice and the extent to which financial constraints would limit uptake.

  Further, if the concentration is already above a safe level and it will take many years to reduce this significantly under any plan, there is the risk that significant feedback effects could be triggered in the meantime—such as the release of additional greenhouse gases from thawing permafrost. A precautionary plan would therefore also need to investigate reflection options.

  Such a plan would place emphasis on managing risk, especially feedback effects. These are triggered by what might be termed the Apparent Concentration—the warming effect felt today as compared to that which can ultimately be expected. In particular, half the warming effect of the greenhouse gases added to the atmosphere since the industrial revolution is suppressed by aerosol pollutants and other agents that reflect sunlight. It will be important to separately manage the net effect of these two, the Apparent Concentration, while maintaining a long-term focus on reducing the greenhouse gas concentration.


  Reflection options receiving serious attention include injecting aerosols into the stratosphere and enhancing the reflectivity of clouds. If these techniques can be proven, each is estimated to have the capacity to neutralise the warming expected from the current concentration of greenhouse gases. They are both estimated to be low cost compared to sequestration and would lower average temperatures relatively rapidly.

  The fundamental difference between sequestration and reflection, however, is that sequestration addresses the root issue (the concentration) while reflection merely treats the symptom (warming). Problems arising from this include:

    — Reflection does not address the acidification of oceans that results from excess CO2 in the atmosphere being absorbed by the sea;

    — Schemes that inject particles into the atmosphere are likely to alter the distribution of rainfall and also cause some reduction in the global quantity of rainfall (as reflecting sunlight is not that same as reducing the CO2 concentration); and

    — Many reflection techniques will need to be replenished constantly over their lifetime and, if this is not kept up, extremely rapid warming could ensue.

  Even if the physical effects were considered an acceptable near-term trade-off, the haunting concern lying behind reflection is that its use could severely undermine incentives for both sequestration and abatement such that fair and affordable action on these would not be undertaken in the near term. Reflection schemes may be low cost but if the concentration needs to be lowered from its present level, someone will ultimately have to pay for this. Deferring abatement and sequestration passes debt and risk to future generations.

  Recognition of the degree of climate change risk currently being run carries profound implications. Not least is that stopping all emissions now would not be enough to prevent dangerous levels of warming if 350 ppm of CO2 turns out to be as important a threshold as Hansen believes: the gases already released would cause this. Restoration of the atmosphere to a safe set of conditions will in any case require very significant and sustained investment in sequestration, whatever shape the new plan eventually takes.

  The societies that spawned the activities producing greenhouse gas emissions have spectacularly failed to manage the risks arising from them to date. A current abatement-only plan that leaves so much to chance, and the absence of an adequately researched alternative plan, is inconsistent with the FCCC requirement for precaution. It is important to acknowledge there has been serious systemic failure and that continuing in some form of denial would be dangerous.

  The atmosphere is a life-sustaining system and it is crucial that any new plan is developed and implemented under the intent of stewardship and not as a geoengineered response. Stewardship would have a primary focus on protecting and restoring the atmosphere by reducing concentrations.


  Restoration focuses on identifying the volumes of carbon that need to be extracted from the atmosphere and allocating the costs of achieving this. A crucial step in this process is determining a concentration governments are willing to deem acceptable—an Accepted Concentration. This would define a total volume of greenhouse gases above pre-industrial levels that was considered reasonable for the atmosphere to carry on a long-term basis. Allocating each nation a fair share of this Available Capacity would logically be based on some metric of cumulative emissions and population.

  That process would also quantify what volume of greenhouse gases is in excess at present and allocate responsibilities for sequestering it among nations. If governments set the Accepted Concentration such that CO2 levels would be 350 ppm, that would require about 35 ppm of CO2 to be sequestered and would result in a bill for historic excess emissions of about US$10 trillion if afforestation was used. The United States' share of this would be similar to the US$3 trillion in banking losses currently being absorbed, and Europe's bill would be much the same.

  Looking forward, if the atmosphere no longer has the capacity to safely accept additional emissions on a long-term basis, then it follows that further rights to utilise atmospheric capacity can only be temporary in nature. Permits for temporary storage can provide a means of reconciling protection of the atmosphere with the time required for economies to "decarbonise", if they are otherwise appropriately constrained. Temporary Storage Permits would authorise additional emissions on condition that the emitter pays to bring that carbon back down if later required. These would be in place of Kyoto-style permits and limitations on the storage period would be the critical discipline.

  Developed countries have a financial incentive to delay determining an Accepted Concentration and so requirements for sequestration spending. An important countermeasure would be for nations to agree to pay fees for temporary storage. Total fees for new emissions (per tonne of carbon) would rise to the cost of sequestration during a transition period.

  As the cumulative emissions of developing countries are low by any measure, they would pay no storage fees during the transition period. All storage fees would be used to fund sequestration projects, with proposals scored on multiple counts to maximise available co-benefits, such as enhanced biodiversity.

  Two factors make storage possible. One is the lag between emissions being produced and higher temperatures being felt. The other is the cooling effect provided by aerosols and other reflective agents. However, storage capacity is limited and a considerable proportion is already being used. The further the system is pushed, the greater the risk of triggering feedback effects.


  Avoiding dangerous climate change will require integrated planning across two distinct timeframes. The long-term focus on cutting emissions and sequestering carbon involves extended negotiations among governments and could be the enhanced role of the FCCC.

  In the meantime, a focus is needed on ways to keep temperatures below levels that are dangerous or might trigger significant feedback effects. If an Atmosphere Regulatory Commission (the Commission) were also established, it could have the hands-on role of managing the Apparent Concentration so as to present the least risk at any time, consistent with an overarching goal of restoring the atmosphere. It would also determine how much temporary storage is to be made available, and for how long.

  The Commission would focus on three climate response measures: sequestration and two forms of reflection—traditional aerosol emissions and reflection projects. In this context, reflection would provide a continuum of options ranging from more active management of aerosols already being produced, through to emergency measures involving large-scale intentional reflection projects. It would assess climate change risk and response options, and then weigh whether the risks and costs of proceeding with a particular plan or intervention would lower climate change risk overall.

  The Commission would first take account of the efforts made by governments to abate and sequester. It would also directly contract for sequestration projects itself, using the funds derived from storage fees that would pass to it. If abatement and sequestration efforts proved insufficient to hold the Apparent Concentration within acceptable bounds, the Commission would need to consider whether any reflection option would lower the overall risk.

  While the Commission need not undertake technology research or build infrastructure, it would be the sole potential purchaser of any reflection services. Private developers would be excluded from operating reflection services and no tradeable credits of any form would be recognised for reflection projects. As a check against the Commission's monopsony power, it would be subject to the highest degree of disclosure at all times.

  Where precisely to locate the Commission is an important question. Placing it outside the FCCC could raise expectations that reflection options will be used, and so reduce the incentives for sequestration. However, separation of the Commission from the FCCC would appear to offer a considerable advantage overall. By providing greater transparency and accountability, it would help deter governments from favouring reflection options simply to avoid higher cost abatement and sequestration. It would also separate out functions that will need to operate at a faster pace and under a different culture to that the FCCC has worked to.

  Constituting the Commission will likely require a new international treaty. The Law of the Sea provides a precedent for more detailed regulation, whether under a UN treaty or alternative arrangements. Reflection activities would initially be regulated by way of two interlocking moratoria. The first would restrain all field trials until minimum conditions necessary for these were established and a second would cover all projects over and above this level. Parties gaining from a reflection project relative to other parties would compensate those that suffer losses, and project sponsors would be liable for harm arising from any scheme.


  While a number of factors make it realistic to plan for the cooperative governance of reflection, it is important to confront the potential for unilateral deployment and conflict arising from its use. A clear driver for unilateral action would be if one region were significantly affected by climate change and felt the international community was responding too slowly. Developing nations will in general suffer soonest from the more serious effects of climate change. The prospect that a small group of developing countries could deploy reflection schemes shifts the balance of power such that the pace of climate change responses in general will tend to better align with their preferences.

  In another scenario, financial factors could drive a group of developed countries to act independently as a way to sideline negotiations with developing countries and simply impose a new order. Large-scale reflection also has the potential to be a "dual use" technology, capable of modifying the weather of a particular region to suit one group of countries at the expense of others. A worst-case scenario for environmental risk would be if a number of competing weather modification projects were to be launched in parallel, each operated independently, with uncoordinated objectives and synergistic effects managed on the hoof.

  There is also the disturbing potential for new arrangements to be cooperative, but at the expense of future generations. This would not result from the reflection deployment itself, but the absence of a linked commitment to sequester excess emissions. Under such a scenario, developing countries would be offered a much greater volume of enduring emission permits so long as developed countries were excused from having to sequester their excess emissions in the medium term.


  Even if a Commission were established in a timely manner and in full form, non-governmental organisation would play a vital role monitoring and checking the regulator. A foundation for successful advocacy would be the capability to monitor the atmosphere as a whole, set thresholds for sustainability, account for performance against these, and devise restoration plans. It is proposed that the production of an integrated set of information be the focus of a new entity that might be called the Atmosphere Restoration Trust (the Trust). Its tasks would include the following:

    — State of the Atmosphere Reports: would establish and then regularly update a comprehensive set of records on the atmosphere;

    — An Atmosphere Restoration Plan: is required to chart the path to an Accepted Concentration and show how the Apparent Concentration will be managed during the transition; and

    — Financial and Economic Analysis: would include contributions to the ongoing design of permits for temporary storage, and to defending the interests of future generations from being discounted in value.

  Both the Commission and entities such as the Trust are just interim measures. Sustainable governance will require enforcement provisions and the establishment of a supranational regulator. This will involve the construction of a new set of international understandings, entailing compacts in respect of international justice, international trade, and military intervention. The place of those negotiations needs to be considered alongside demands arising from the overlapping issues of water, food and fuel security, and humanitarian concerns generally.

  This submission is based on the Council's publication, Restoring the Atmosphere, August 2009.

  Thank you for the opportunity to submit and we would welcome the opportunity to provide oral evidence by teleconference.


Actual Concentration: The total concentration of all long-lived greenhouse gases resident in the atmosphere at a particular time.

Apparent Concentration: The concentration that corresponds to the radiative force acting on the Earth due to human intervention, at a particular time.

Long Term Concentration: The total projected concentration after sequestration of all long-lived greenhouse gases resident in the atmosphere at a specified date at least 100 years in the future.

Accepted Concentration: A concentration governments collectively deem to be an acceptable Long Term Concentration.

Available Capacity: The difference between the pre-industrial concentration and the Accepted Concentration.

Excess Emissions: The quantity of emissions resident in the atmosphere that is in excess of the Accepted Concentration.

Enduring Emission Unit: A permit to emit a tonne of CO2 equivalent gases.

Temporary Storage Unit: A permit to emit a tonne of CO2 equivalent gases and the obligation to sequester a tonne of CO2 equivalent gases at a later date—pre-specified or subject to notification.

Temporary Sequestration Unit: A credit recognising the temporary sequestration of a tonne of CO2 equivalent gases. It expires on a pre-specified date unless proof of continued storage can be demonstrated.

Enduring Sequestration Unit: A credit recognising the semi-permanent sequestration of a tonne of CO2 equivalent gases.

Storage Fee: At the time a Temporary Storage Unit is utilised (though the release of emissions under it), a storage fee is payable on each tonne of long-lived greenhouse gases, according to the rate set for it by the Commission.

December 2009

11   This is a measure of the concentration of all greenhouse gases, expressed on a carbon dioxide equivalent basis, in "ppme". Concentrations of CO2 alone are expressed as "ppm of CO2". Back

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2010
Prepared 18 March 2010